Effective Date: January 2019
Pursuant to the GDPR, Privowny is the data controller with respect to any personal data collected and processed as part of provided services or in connection with our Website.
1. Personal Data we collect
- Name and surname;
- Email address;
- Company name;
- Business function;
- The message you left on the “Contact” page.
We also collect technical data relating to your use of the Website, notably including the IP address (collected automatically when you access the Website).
We collect your personal data when you visit and otherwise use the Website, as specified above, when you provide us with such information using electronic or hard copy forms, contact us by telephone, fax, email, post or via the “Contact” page or any other mean.
2. Why and on which basis do we collect personal data?
Privowny collects, uses and stores your personal data on the basis of legitimate interest, in order to provide you with the Service on our Website, conduct our business functions and activities, improve and ensure the security of our Website, improve and customize our Website as well as products and services we provide, send direct marketing and other communications related to our business, products and services, provide you with information, products and services that you request from us, provide you with a bug report, collect data of candidates, communicate with media and press services, comply with our legal obligations, and for other legitimate purposes permitted by Data Protection Laws.
3. Data retention
We store your personal data for as long as necessary to provide you with the services you have requested, or for other purposes such as complying with our legal obligations, resolving disputes and enforcing the agreements to which Privowny is a party.
Please note that Privowny is required by applicable law and/or regulations to retain some types of information for certain periods of time (e.g. statute of limitations). If your personal data is no longer necessary with respect to purposes for which it is processed and Privowny has no legal obligation to retain it, subject to the prior exercise of your right to deletion, we will erase it from our systems and destroy all record of it.
|Relevant Personnal Information||Retention Period|
|Contact Data||3 years from data collection or last contact with you|
|Data related to measurement of the traffic and personalization of the Website, managing cookies||13 months|
|Data related to requests to access or rectify data, or oppose data processing||3 years from your request|
|Data related to potential employees||2 years from last contact with candidate|
Privowny uses a session cookie for our Contact page (Kirby) which is a third-party cookie. This cookie has an indefinite lifetime: it depends on how long you stay on the contact form on the “Contact us” page. This cookie expires when you close your browser.
Its aim is to create a token which validates your message sending and is therefore mandatory for your use of the “Contact page”. It cannot be blocked.
5. Sharing your personal data
Privowny protects your privacy. As a result, we do not sell or rent or otherwise share any of your personal data with third parties for advertising or commercial purposes. We only disclose your personal data to third-party processors and vendors that provide products and services to us, or to other third parties where expressly instructed by you, as the case may be.
In this respect, we only use carefully vetted third-party processors and vendors, located inside or outside of the European Union territory, to provide us with certain products or services. Our third-party data processors are compliant with the GDPR, in particular with respect to data security and confidentiality, and only process your personal data on our behalf and under our written instructions in order to offer the contracted services to Privowny.
Please find here the list of our processors:
|Processor||Aim||Personal data we collected||Contact|
|Amazon Web Services||Hosting our platform||What you wrote on the “Contact” page||Data Protection Officer Amazon Web Services-EMEA SARL, 38 Avenue John F. Kennedy, L-1855 Luxembourg|
We may also share your personal data with official authorities and government bodies where required to do so by applicable law. In such event, we endeavour to only disclose the necessary information to comply with our obligations under applicable law.
6. Transfer of your personal data outside of the EU/EEA
A Transfer may occur if our processors and/or vendors are located outside of the EU/EEA, if we outsource certain activities outside of the EU/EEA or if you use the Website in a country located outside of the EU/EEA.
Where required by applicable privacy and Data Protection Laws, we take steps in order to ensure any Transfer is performed in compliance with the appropriate organizational and technical means (including e.g. European Commission’s standard contractual clauses for data transfers, or European Commission’s adequacy decisions).
7. Your rights
Under the GDPR, you have rights that apply to your personal data, including right to access, rectify, erase, restrict or object to data processing, or have the personal data that we hold about you ported to another data controller or service provider.
You can request to access and receive a copy of the personal data that we hold about you at any time.
Under certain circumstances provided by Data Protection Laws, we may deny you such access. If we refuse your request to access your personal information, we will provide you with reasons for the refusal where we are required by Data Protection Laws to disclose those reasons.
Privowny uses its best efforts to ensure that any personal information we collect and hold is accurate, complete and up-to-date. In this respect, you undertake to provide us with true, accurate, current and complete information about yourself as requested, and properly update the information provided to us so that it remains accurate, complete and up-to-date at all times.
Alternatively, please notify us regarding any change that applies to the personal data you provided us with, notably by contacting us using the details provided below if you believe that the personal information is inaccurate or incomplete, and we will correct the information.
8. Security and confidentiality
Privowny values your privacy and use its utmost efforts to warrant the security and confidentiality of any information you may provide us with. Consequently, we implemented appropriate technical and organizational measures to ensure that personal data we hold, whether in hard copy or on our computer systems, remains protected at any time against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access.
Privowny France SAS
Europarc de Pichaury Bât B4,
1330 avenue JRGG de la Lauzière,
In case of dispute, you, or an association you designated for this purpose, as provided by Data Protection Laws, have the right to lodge a complaint to a competent data protection authority such as the French Data protection agency (CNIL - cnil.fr.)
A complete list of all the European Data Protection Authorities and how to contact them is available at: